Arbaugh v. Y & H Corp.
546 U.S. ___ (2006) (2006)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A statutory limitation on a federal cause of action, such as Title VII's 15-employee numerosity requirement, is an element of a plaintiff's claim for relief and not a jurisdictional prerequisite, unless Congress clearly states that the limitation is jurisdictional.
Facts:
- Jenifer Arbaugh worked as a bartender and waitress at the Moonlight Cafe, a New Orleans restaurant owned and operated by Y&H Corporation, from May 2000 through February 2001.
- Arbaugh alleged that Yalcin Hatipoglu, one of Y&H's owners, sexually harassed her.
- As a result of the alleged harassment, Arbaugh claimed she was constructively discharged from her position.
- Throughout the pretrial proceedings and during the trial itself, Y&H Corporation did not dispute that it met the 15-employee threshold required to be considered an 'employer' under Title VII.
- In its initial court filings and in the pretrial order, Y&H Corporation admitted the court's jurisdiction over Arbaugh's claims.
Procedural Posture:
- Jenifer Arbaugh sued Y&H Corporation in the U.S. District Court for the Eastern District of Louisiana for sexual harassment under Title VII and state law.
- A jury found in favor of Arbaugh and awarded her $40,000 in damages, and the trial court entered judgment on the verdict.
- Two weeks later, Y&H filed a motion to dismiss for lack of subject-matter jurisdiction, arguing for the first time that it was not an 'employer' under Title VII because it had fewer than 15 employees.
- The District Court, treating the requirement as jurisdictional, granted the motion, vacated the judgment, and dismissed Arbaugh's entire action.
- Arbaugh, as appellant, appealed to the U.S. Court of Appeals for the Fifth Circuit, which affirmed the trial court's dismissal.
- The U.S. Supreme Court granted certiorari to resolve a circuit split on the issue.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does Title VII's requirement that an 'employer' have fifteen or more employees limit a federal court's subject-matter jurisdiction, or is it an element of a plaintiff's claim for relief that is waived if not challenged in a timely manner?
Opinions:
Majority - Justice Ginsburg
No. The numerical threshold contained in Title VII's definition of 'employer' is an element of a plaintiff's claim for relief, not a jurisdictional requirement. Subject-matter jurisdiction objections can be raised at any time and cannot be waived, whereas a defense based on an element of a claim, such as the failure to state a claim under Rule 12(b)(6), is waived if not raised before the conclusion of a trial on the merits. The Court reasoned that the 15-employee requirement appears in a definitional section of Title VII, 42 U.S.C. § 2000e(b), not in its jurisdictional provision, § 2000e-5(f)(3). Treating such a requirement as jurisdictional would be inefficient and unfair, allowing a defendant to wait until after receiving an adverse verdict to challenge it. Therefore, the Court established a bright-line rule: unless Congress clearly designates a statutory limitation as jurisdictional, courts should treat it as a nonjurisdictional element of the claim. Because Y&H failed to challenge the employee count in a timely manner, it forfeited the objection.
Analysis:
This decision provides a crucial clarification on the distinction between jurisdictional issues and elements of a claim, creating a strong presumption against classifying statutory limitations as jurisdictional. By establishing a 'clear statement' rule, the Court places the burden on Congress to specify if a requirement is intended to limit a court's fundamental authority. This ruling promotes judicial efficiency and fairness by preventing defendants from strategically withholding a challenge until after a trial on the merits, a practice often referred to as 'sandbagging.' The principle extends beyond Title VII, affecting the interpretation of numerous other federal statutes that contain similar threshold requirements for their application.
Unlock the full brief for Arbaugh v. Y & H Corp.